Recent blog posts

Whilst the ancestry of the FAA goes back to the 1920’s  the “Modern” FAA essentially started with the Federal Aviation Act of 1958. A different level of aviation safety was to be found at this time with a number of accidents driving congress to mandate a new independent regulatory body with authority to address safety issues through the power of rulemaking.

Today the FAA has a broad reach with authority for all aspects of aviation related activity in the United States.

Meanwhile over in Europe the Joint Aviation Authority (JAA) forerunner of European Aviation Safety Agency (EASA) can show its origins back to the early 1970’s. 

The original purpose of the JAA was to provide oversight and guidance related to the design and certification of large Aircraft, Engines and APU’s. It was during these early days that an alignment started to take place between the FAA and the JAA to introduce common certification codes for large aircraft and aircraft engines. Such alignment contributed to the common acceptance of Aircraft Parts and Alliances by participating entities.

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Sofema Aviation Services www.sassofia.com looks at the challenges of maintaining an effective supply change compliant with EASA, Best Practice & Due Diligence.

What is it all about

Amongst other proposed changes EASA looked at enhancing the supplier evaluation procedure to provide clarity together with a strong and robust process.

So what happened

Unfortunately, as is currently happening in many regulatory related areas EASA steps back and several years pass. (This story is not a positive reflection on the role of EASA – however it is unlikely that this will change or improve in the near term!)

Tagged in: EASA NPA 2012-03
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What is Production Planning?

So lets start by saying that production planning has nothing to do with the operator (so not to confuse with the maintenance planning activities which sit within the operators remit).

Production Planning belongs to the Part 145 Production Organisation – To be effective it needs to interface with the PART M Continuing Airworthiness Management Organisation (CAMO) and ideally to be able to influence the CAMO in a positive way.

Production Planning could be considered an art in that we need to effectively bring together a number of disparate elements to obtain the best possible result in the minimum time whilst recognising the importance of Safety, Human Performance and Fatigue Risk Management Systems (FRMS).

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We usually overestimate our ability to communicate and this can even be magnified when the communication is with people who we know well. Often because we believe we have a deeper level of understanding than is actually the case.

We should try to speak to people as individuals even when they are in groups. Do not allow yourself to be distracted and focus on delivering your message in a genuine way with both enthusiasm and energy.

Knowing the Subject Matter is Essential

You really do need to know the subject, this is a fundamental part of establishing rapport and respect with you audience (both of which are essential for effective communication).

Pay particular attention to your audience and strive to build the connection, adjust your message so that it resonates with the audience, focus on getting your message across without overdoing, seek questions as a way of ensuring the message is received.

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SofemaOnline – www.sofemaonline.com  considers the role of Dynamic Communication

Communication is actually a very dynamic process going far beyond the words we say. Whilst Communication essentially encompasses both language and speech it includes also the ability to share our thoughts and experiences in a meaningful way using other ways and means, for example body language.

Another way to look at Communication is to accept that it is a broadband process which is essentially made up of many single band processes. Consider that the actual speech used as well as each different type of non-verbal aspect can be considered as single elements that together make up the broadband process of communication.

We are able even without realizing that it is taking place to process multiple modes of communication is an automatic, part of our problem is that we do not even need to hear all of what is being said before we have begun to formulate our response!

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Sofema Aviation Services www.sassofia.com considers an EASA Compliant Maintenance Planning Process. 

Maintenance has come a long way since the early days when maintenance programs owed more to the perception of the maintenance needs, as opposed to the analyzed and justified needs. In addition the role of the regulator was also minimal, and in part developed as a result of events, incidents and accidents. 

During the end of the first half of the 20th century regulations began to strengthen and the aircraft manufacturer was seen as the appropriate source of the maintenance program development. The early attempts at effective maintenance (in the 1960’s) saw time limits developed which resulted in aircraft being progressively dismantled, in what became know as Hard Time primary maintenance.

All hard time components were then routed through an overhaul process and after an appropriate restoration process were considered as zero timed. (Means they were considered as zero life and good to go again) - Following investigations into the effectiveness of the Aircraft Maintenance Process, by both the FAA and several airlines, a number of determinations were made.

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Steve Bentley MD of Sofema Aviation Services www.sassofia.com – explains

A type certificate holder (TCH) can produce parts for its airplanes through the process of the manufacturers authorisation FAR Part 21 / EASA Part 21 Subpart G has the authorization to manufacture those parts on the basis of its type certificate, and production certificate.

However organisation who are authorised as PMA-holding manufacturers are permitted to make replacement parts for aircraft, even though they are not the original manufacturer of the aircraft. An applicant for a PMA applies for approval from the FAA.

An STC is a certificate. It defines the product design change, states how the modification affects the existing type design, and lists serial number effectivity. It also identifies the certification basis, listing specific regulatory compliance for the design change. Information contained in the certification basis is helpful for those applicants proposing subsequent product modifications and evaluating certification basis compatibility with other STC modifications.

Tagged in: FAA Manufacturing PMA STC TCH
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Bridging Checks Introduction

Why would we want to carry out a Bridging Check?

Typically because we have recently acquired a “new to our organisation” aircraft and it is on a different maintenance schedule.

A bridging check is normally required to address tasks which have either not been done by the previous operator (maybe they are not applicable for a particular operator) or alternatively the tasks may have been done at different intervals when directly compared with your existing Maintenance Programme or Schedule.

A ‘bridging check’ is not in itself a maintenance package; rather it is the result of a detailed analysis of the pre and post transfer tasks to identify any differences which need to be addressed during the transfer bridging check.

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Sofema Aviation Services www.sassofia.com and SofemaOnline www.sofemaonline.com

Offering Regulatory Compliant Training for FAA Repair Stations In Classroom & Online

Concerning FAA -EASA Bilateral Agreement

The FAA notes that some part 145 repair stations have European Aviation Safety Agency (EASA) certifications. EASA part 145 contains licensing and training requirements for Approved Maintenance Organizations (AMO) that perform maintenance on articles of those operators under the regulatory control of European Union (EU) Member States.

These EASA part 145 requirements can affect FAA part 145-approved repair stations that also have EASA approvals; since EASA requires maintenance human factors training as part of the Bilateral Aviation Safety Agreement (BASA) and Maintenance Implementation Procedures (MIP) with the United States.

The FAA training program may include the requirements of other civil aviation authorities as long as the part 145 requirements are also met.

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It is not uncommon for the operator to require the CAMO to maintain the reliability program to essentially demonstrate the minimum compliance of the regulatory requirements. Missing the opportunity to foster a genuine desire to engage with a serious investigate process related to the understanding of negative trends and take efficient corrective measures.

Possibly a major reason for this behaviour is related to a lack of understanding by the operator regarding the philosophical reasons related to the effective implementation of a fully active statistical process control. Unfortunately, the focus is on “living and surviving from day to day” solving problems without spending sufficient time on dealing with the underlying causes.

The benefit of a fully integrated Reliability program is that it does not over react to single events rather the focus moves to trends and system related problems.

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Complete your repair station training with SofemaOnline.com

SofemaOnline (SOL) – Virtual Aviation Academy - The “Go To” site for online training

SOL is supported by European Aviation Institute (EAI) an EASA Part 147 approved Maintenance Training Organization (MTO) with Certificate of Approval No RO.147.0003.

Our trainings are designed to be effective and to help you reach the correct level of understanding in the comfort of your own home or office.

FAA 14 CFR Part 145 Detailed Initial Training has been developed for Quality Managers, Technicians, Mechanics, and Repairmen who are either currently involved in a repair station or intend in the future to establish a 14 CFR Part 145 repair station.

Tagged in: CFR FAA Part 145 SOL
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Considering the Fundamental EASA QA/ QC Relationship

The Quality Manager (Compliance Manager) is responsible for the independent assessment of compliance – not to loose sight that this process is additional and should be considered as a Safety Net rather than a primary method of ensuring compliance.

The Continuing Airworthiness Manager (CAM) is responsible for the QC Activities related to the compliances which are validated during the ACAM process.

Building on this understanding means that an effective oversight of an effective process will focus on the physical management, delivery and maintenance of competence within the system of control.

The Regulatory Point of View

Tagged in: ACAM KREs QA QC QMS
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What does the FAA Say about Limit of Validity?

The limit of validity (LOV) represents an operational limit based on fatigue test evidence that supports the maintenance program. The FAA defines the LOV as “the period of time (in flight cycles, flight hours, or both) up to which it has been demonstrated by test evidence, analysis and, if available, service experience and teardown inspections, that widespread fatigue damage will not occur in the airplane structure.” It is further defined as the point in the structural life of an airplane at which there is significantly increased risk of uncertainties in structural performance and probable development of WFD.

Once the airworthiness limitations containing the LOV are approved by the FAA, an airplane may not operate beyond the LOV.

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Posted by on in Regulatory

Whilst the Operators CAMO is responsible for the delivery of an effective and viable maintenance planning process, it is the EASA part 145 Aircraft Maintenance Organisation (AMO) which has the responsibility to perform the maintenance in accordance with the work package.

EASA AMP Obligations

EASA requires Operator Reviews of Validity and Effectiveness of the AMP  - EASA Annex I – Part M - Subpart C - M.A. 302 Aircraft Maintenance Programme - (g) … The aircraft maintenance programme shall be subject to periodic reviews and amended accordingly when necessary. These reviews shall ensure that the programme continues to be valid in light of the operating experience.

Operators are able to strongly influence the success of a continuous development of scheduled maintenance program data but providing a virtuous circle of feedback to the Type Certificate Holder (TCH), A continuous review of TCH and Original Equipment Manufacturer (OEM) service bulletins, reliability data, service letters, airworthiness directives provides source material for optimisations.

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Maintenance Planning Document (MPD) – The MPD is essentially generic across a particular fleet, is issued by the aircraft manufacturer and applies to many aircraft, it is not customized and several (hundreds of) tasks are dependent for example on the aircraft modification status and its serial number.

It cannot under any circumstances be considered as a final list of tasks for a given tail number.

Aircraft Modification Status – The applicability of multiple tasks may be affected by the aircraft modification status. (The MPD may list a task as “pre mod” or “post mod”.)

To correct set the tasks we must know the mod status of the aircraft in order to know which tasks are applicable and should be carried out.

Also, the aircraft may have custom modifications embodied, which often come with their own maintenance tasks. (Via Supplemental Type Certificate (STC) controlled by Part 21 Subpart J Design organisations)

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When a maintenance program is developed, it includes tasks that satisfy the criteria for both applicability and effectiveness.

The applicability of a task is determined by the characteristics of the component or equipment to be maintained.

The effectiveness is stated in terms of the consequences that the task is designed to prevent. The basics types of tasks that are performed by maintenance personnel are each applicable under a unique set of conditions.

Tasks may be directed at preventing functional failures or preventing a failure event consisting of the sequential occurrence of two or more independent failures which may have consequences that would not be produced by any of the failures occurring separately.

Maintenance Program task types include:

(1) Inspections of an item to find and correct any potential failures;

(2) Rework/remanufacture/overhaul of an item at or before some specified time or age limit;

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Compliance Auditing brings with it the daily challenge of ensuring that the organisation remains at all times fully compliant with both internal and external obligations.

The Audit Management, Control and Oversight system should ensure that the established safety and quality procedures are fully complied with.

In addition :

a)     To plan and deliver audits

b)     To review findings

c)     To perform root cause analysis and develop additional actions where necessary (under the specific control or guidance of the business area owner of post holder)

In an effective Quality Management System QMS monitoring is a continuous process. It is essential to ensure robust and continuous oversight of all internal processes, and procedures.

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Let’s consider the difference between Assessment & Audit

Assessment

The evaluation process used to measure the performance or effectiveness of a system and its elements.

Our goal is to perform an assessment of the auditing process follow up to determine both the cost effectiveness and overall value to the business.

Audit

An EASA Audit is a systematic and independent examination to determine whether quality activities comply with external regulatory requirements and internal organisational specifications and whether these specifications are implemented effectively.

A primary indicator of a poor or failing system is repeat findings or findings which should be addressed at a lower level – for example the Competent Authority should not identify problems which are normally expected to be found within the internal Quality Assurance System audit process.

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The ability to successfully identify and address the root cause is not a given and like many activities benefits from improved knowledge experience and development of individual competence.

Typically it is only by monitoring over time that we are able to confirm that the mitigation's which have been developed as a result of analysed root cause have done the job. However we can draw a conclusion based on our understanding of the analysis and actions which have taken place to assess if we have confidence in the steps which have been taken.

Any shortfall in expectation could for example cause the finding to be re-opened for additional analysis.

Some of the reasons that the true root cause has been miss identified are considered here :

a) Root Cause Analysis (RCA) based on assumptions rather than on objective evidence. It is essential to ensure that all data is accurately classified and clearly understood in relation to the observed facts.

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Please consider that just because a product meets for example compliance with ISO 9001-2015 objectives does not automatically mean it is safe. (Just as not having an accident can be taken as meaning that we will not have an accident in the future.)

In reality the key aspect becomes our ability to measure risk and exposure. Quality systems audits consider gaps related to compliance with both external regulations and internal organisational process and procedures.

Quality Assurance and Risk Assessment

The first point to make is that the term “risk” subjective whereas the role of an EASA regulatory driven audit is to assess compliance with a standard not an opinion so this creates a challenge.

So when a discrepancy is identified it creates a number of questions

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